Inside Government Contracts

Procurement Law and Policy Insights

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On February 17, 2026, the Federal Acquisition Regulatory Council released a Notice of Proposed Rulemaking, proposing amendments to the FAR to implement Section 5949 of the FY23 National Defense Authorization Act (“NDAA”).  Section 5949 prohibits executive agencies from obtaining semiconductor parts, products, or services traceable to certain named Chinese companies – currently, Semiconductor Manufacturing International…

On February 18, 2026, the General Services Administration (“GSA”) issued a proposed revision to the certifications that federal financial assistance recipients or applicants must make in order to register in the System for Award Management (“SAM”), adding certifications related to diversity, equity, and inclusion programs; immigration; and national security.  The proposed revision also addresses applicability…

On January 23, 2026, the Office of Management and Budget (OMB) issued Memorandum M-26-05 “Adopting a Risk-based Approach to Software and Hardware Security,” which rescinds a previous Biden Administration’s requirement for all federal agencies to obtain a self-attestation from software producers in the “Common Form” developed by the Cybersecurity and Infrastructure Security Agency…

A recent decision from the Armed Services Board of Contract Appeals (ASBCA) is a timely reminder that, when it comes to stop‑work orders, the clause the government actually invokes—not the one it later wishes it had—can be outcome‑determinative. In Wolverine Tube, Inc., ASBCA No. 63877 (Jan. 22, 2026), the Board rejected the Air Force’s attempt…

On January 23, 2026, Vice President Vance announced the administration’s intent to expand the “Mexico City Policy.”  First established by President Reagan, the Mexico City Policy originally prohibited foreign non-governmental organizations (“NGOs”) from using funds to “promote abortion as a method of family planning in other nations.”  The policy was repealed by the…

As the federal government focuses on securing reliable supplies of critical minerals, stockpiling has emerged as a key policy tool, alongside direct investments in private enterprises and expanded funding programs for industry.  The National Defense Stockpile (“NDS”) currently serves as the federal strategic reserve of materials needed for national defense, including critical minerals, and the…

The past month has marked a series of announcements from the Department of War (the “Department”) emphasizing rapid deployment of artificial intelligence (“AI”) industry partnerships.  These announcements signal opportunities for not only the defense industrial base, but also nontraditional defense contractors focused on technology and data.

On January 9, 2026, the Department released two key…

Among the most challenging areas of regulatory compliance for federal contractors are cost accounting and cost and pricing data disclosure requirements.  Indeed, many companies place guardrails on the nature and scale of their business relationships with the U.S. government precisely to avoid the application of these requirements.  In a move that seems consistent with the…